Statement of Practice 1 (2002)
Published 6 April 2002
© Crown copyright 2002
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Corporation Tax Self Assessment enquiries: Finance Act 1998 Schedule 18 Paragraph 24: enquiries remaining open after expiry of the period within which a notice of enquiry may be issued solely because of an unagreed valuation for chargeable gains purposes.
The Statement of Practice applies where, in the case of an enquiry into a return made under paragraph Finance Act 1998 Schedule 18 Paragraph 3 all of the following occur:
- HM Revenue and Customs (HMRC) has given notice under Finance Act 1998 Schedule 18 Paragraph 24 of their intention to enquire into that return
- the enquiry remains open after the expiry of the period within which that notice had to be issued (‘enquiry period’)
- the enquiry remains open solely because of an unagreed valuation for chargeable gains purposes
In such circumstances HMRC will not, as a matter of practice, raise further enquiries into matters unrelated to the valuation or the chargeable gains computation unless the circumstances are such that, had the enquiry already been completed, an officer could have made a discovery within the meaning of Finance Act 1998 Schedule 18 Paragraph 41. This practice applies only to valuations made for the purpose of computing chargeable gains of companies and other bodies within the charge to Corporation Tax.
This practice does not alter or fetter HMRC’s right to ask further questions or make additional enquiries on matters in connection with, or consequential to, the obtaining of the valuation which were not raised when the valuation was first referred to Shares Valuation Division or the Valuation Office Agency.